South Korea Gazettes Presidential Decree Amending Enforcement of International Tax Adjustment Act

The South Korean Official Gazette Feb. 27 published Presidential Decree No. 36128, partially amending the enforcement decree for the International Tax Adjustment Act. The decree includes measures: 1) allowing a multinational enterprise (MNE) group constituent entity’s allocation of specific taxes, like from a permanent establish (PE), to entities like other constituent entities, joint ventures, or PEs; 2) providing rules for domestic top-up tax and effective tax rate calculation under OECD Pillar Two; 3) specifying allocation of top-up tax among domestic constituent entities, including when the MNE group lacks net global minimum tax income, but has incurred domestic top-up tax; 4) ...